New USDE Guidance on Federal Programs Substitute Time

New USDE Guidance on Federal Programs Substitute Time and Effort System Cory Green, Chief Grants Administrator David Mc. Laughlin, Federal Fiscal Compliance Officer December 19, 2012 © 2012 The Texas Education Agency

What Is Time-and-Effort (T&E) Reporting? Paying only proportionate share of personnel costs with federal funds Salaries charged to federal funds? Time distribution records required Contractors not subject to time-and-effort requirements Two types of records: ◦ Semiannual certification ◦ Personnel activity report (PAR) 2

Semiannual Certification Requirements After-the-fact record (dated) Accounts for total compensated activity Completed at least every six months Signed by supervisor with knowledge of employee Coincides with one or more pay periods Traditionally applied to employees supported by a single cost objective 3

PAR Requirements After-the-fact record (dated) Accounts for the total activity for which employee compensated At least monthly Signed by the employee Must coincide with one or more pay periods Traditionally applied to employees supported by multiple cost objectives 4

September 7, 2012, USDE Guidance: Single Cost Objective Definition: “A function, organizational subdivision, contract, grant, or other activity for which cost data are needed and for which costs are incurred. ” 5 Multiple funding sources may still be single cost objective

September 7, 2012, USDE Guidance: Single Cost Objective Employees supported by single cost objective submit semiannual certification 6 Regardless of whether LEA implements substitute system

Determining Single Cost Objective “The key to determining whether an employee is working on a single cost objective is whether the employee’s salary and wages can be supported in full from each of the federal awards on which the employee is working, or from the federal award alone if the employee’s salary is also paid with non-federal funds. ” 7

Example I: Title I, Part A, and State Funds Supplemental math teacher serves lowachieving students on a Title I campus Paid half from Title I, Part A, and half from state funds Teaching math to low-achieving students can be fully supported under Title I, Part A 8

Example I: Title I, Part A, and State Funds (Cont’d) Single cost objective Only a semiannual certification is required, despite federal/state funding split 9

Example II: Two Sections of IDEA-B Preschool special education teacher splitfunded between IDEA sections 611 and 619 Teaching preschool special education is allowable under both sections. Single cost objective Only a semiannual certification is required, regardless of multiple federal awards 10

Example III: Perkins and State Funds State curriculum specialist develops new CTE courses and initiatives Funded half with Perkins and half with state general funds Single cost objective Only a semiannual certification is required, regardless of split between federal and state funds 11

What Are Multiple Cost Objectives? Employee works on: Multiple federal awards (not meeting single cost objective definition) Federal and non-federal awards (again, not meeting definition) 12

What Are Multiple Cost Objectives? (Cont’d) Indirect/direct cost activities Multiple indirect activities allocated using different allocation bases Unallowable activity and direct or indirect cost activity 13

New USDE Guidance (September 7, 2012) Multiple cost objective employees may submit semiannual certification, if: ◦ LEA submits management certification to TEA ◦ Employee completes schedule and certification ◦ Is in effect for entire 2012 -2013 school year Applies to all LEAs, including ESCs and charters 14

Ed-Flex Waiver Substitute system does not affect Ed-Flex.

LEA Requirement: Management Certification Form on Substitute System page (search for “Substitute System” or follow link from Grants page) LEA must complete/submit form every school year Form submitted by mail as specified on Substitute System page Due February 15, 2013, for 2012 -2013 May be retroactive to July 1, 2012 16

Conditions for Employee Participation Must work on specific activities or cost objectives based on a predetermined, consistent schedule 17 Must currently work on a schedule that includes multiple activities or cost objectives that must be supported by monthly PARs May not work on multiple activities or cost objectives at the exact same time

Employee Schedule Requirements Employee schedule must: • Indicate specific activity/cost objective employee worked on for each segment of employee’s schedule • Account for total hours for which each employee compensated during schedule period • Be completed again/resubmitted if schedule changes by more than 10% 18

Employee Schedule and Certification Employees must complete work schedule and certification Schedule and certification submitted to LEA business office Certification must be semiannual at least Signed by employee and supervisor with firsthand knowledge of employee’s work 19

TEA-Developed Schedule and Certification Auto-calculating spreadsheet Includes all elements TEA auditors require LEAs not required to use TEA form 20 TEA developed sample employee schedule and certification form If LEAs develop own form, must include all required elements

Demonstration of TEA Form All material covered here included in instructions Read instructions first Complete schedule next 21 Spreadsheet includes instructions, schedule, and certificate Finish with certification

Demonstration of TEA Form: Schedule Complete program table (list of programs worked on) 22 Complete name, position, district, schedule period fields Identify time worked on programs each day

Demonstration of TEA Form: Name, position, schedule period, and district info will auto populate certification Entered Manually on Schedule Populates on Certification 23

Demonstration of TEA Form: Programs Room for eight programs, including local funds Use dropdown when possible to list programs Dropdown menu available fields A-E 24 Must list all programs worked on For other programs, manual entry fields F and G

Demonstration of TEA Form: Program Dropdown List Select SOF from dropdown list 25

Demonstration of TEA Form: Manual Program Entry 26

Demonstration of TEA Form: Time Worked Dropdown list for minutes worked, 15 minute increments Manually type brief description of activity Dropdown letter list (A-H) to associate activity with program 27 Document regular daily schedule Program list will update with total minutes

Demonstration of TEA Form: Schedule Row 28

Demonstration of TEA Form: Minutes Dropdown Select period of minutes from dropdown list 29

Demonstration of TEA Form: Activity Description Manually enter activity 30

Demonstration of TEA Form: Associate Program by Letter Select SOF Code (from above) from dropdown list 31

Demonstration of TEA Form: Minutes by Program 32

Demonstration of TEA Form: Schedule with Multiple Rows/Programs 33

Demonstration of TEA Form: Program List with Minutes Charged to Multiple Programs Funding Percentages autocalculate as time is entered 34

Demonstration of TEA Form: Accounting for Lunch accounted for on last row of schedule 35 Lunch minutes are not part of program calculation

Demonstration of TEA Form: Certificate Much content of certificate autofills from schedule Following content entered manually: ◦ Total hours worked ◦ Total lunch hours ◦ Fund codes ◦ Employee signature/supervisor name and signature 36

Demonstration of TEA Form: Identifying Information 37 Name, position, schedule period, and district information auto fills from schedule

Demonstration of TEA Form: Hours Manually enter total number of hours worked Manually enter total number of lunch hours (actual hours, rather than lunch periods) Check the following: ◦ Total hours times 60 (a) equals total minutes 38

Demonstration of TEA Form: Hours Manual entry Auto filled After entering hours, ensure (a) equals (b) 39

Demonstration of TEA Form: Fund Codes Enter the appropriate Fund Code for each SOF 40

Resources and Further Information Chief Grants Administrator section of the Grants page of TEA website 41 USDE September 7, 2012, letter Substitute System page of TEA website (search for “Substitute System” or follow link from Grants page)

Questions? Email additional questions to GAFPC@tea. state. tx. us

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